1. Ashley Roughton Nabarro LLP
Moving towards a paper light healthcare system – is this where we’re heading?
Ashley Roughton
Nabarro LLP

2. Programme Design Compliance Ethos
Challenges of a paper light environment

3. Basic Obstacles Mentality Ill-defined filing ethos Loss Accessability
Up-to-date
Maintenance

4. Risks
Scanning issues
Misunderstandings over retention or disposal of property belonging to another
Failure to act on (urgent) instructions
Failure in naming or filing of documents
Security breaches
Business interruption
Non-compliance with requests for information
Obsolescence of firms’ IT systems.

5. Basic Benefits Less or no physical wear and tear on files
Easily accessible …. quicker to access
More space … easier sharing
Easier to deal with expansion
Production costs (copying and printing) minimised immediately … less paper in … less paper out … less paper
Information easily transferrable
Software intervention, time tabling and alarms more easy to construct

6. Design Designing a paperless system Privacy by design
Protection of data by default

7. Design of a paperless system
Scanning
Computer generated document storage
Naming
Filing strategy
Printing rules
Outside constraints
in-out-in rules and compliance
Bouncing

8. Privacy by Design – the seven foundational principles
Proactive not Reactive; Preventative not Remedial
Privacy as the Default Setting
Privacy Embedded into Design
Full Functionality — Positive-Sum, not Zero-Sum
End-to-End Security — Full Lifecycle Protection
Visibility and Transparency — Keep it Open
Respect for User Privacy — Keep it User-Centric

9. Compliance Must be enforced rigorously
Difficulties arise usually because of lack of clear guidelines or procedures
Two distinct issues usually arise:-
Lack of any formal file naming policy
Lack of enough file describers (e.g. filenote/agreement/ and so on).
If file naming is to take place then it must be done by a person who understands
The importance of compliance
The document being filed
The dangers of abbreviation

10. Ethos As a compliment to compliance
Engenders ideas within a corporation that causes all to behave in a particular way
The best form of compliance is wanting to do something
However, to engender the ethos, policies are required:-
over the shoulder
detachable media
download
Version control

11. Over the shoulder
Need be no more than an oft repeated warning that when you read things in public places others may do so too – not a paperless problem.
However an over the should glimpse may amount to a data breach, which could attract substantial fines.

12. Detachable Media
Regularly updated Anti Virus software should be present on all machines from which the data are taken from and machines on which the data are to be loaded.
Encryption to a recommended encryption standard (AES-256).
Mobile devices and/or removable storage containing sensitive or highly sensitive data should not be sent off site.
Specific permission if highly sensitive data are required to be transported via removable media.
Removable media used to store sensitive and highly sensitive data shall only be used by staff who have an identified and business need for them.
Must remain encrypted and must not be transferred to any external system in an unencrypted form.
Data stored on removable media are the responsibility of the individual who operates the devices.
Forgotten encryption passwords will always result in complete re-formatting.
Media should be physically protected against loss, damage, abuse or misuse when in use, storage and transit.
Mobile devices and/or removable media that have become damaged or which are otiose should not just be thrown away – they should be returned to IT management.
Sub-contractor use should be specifically authorised.

13. Download Policy
Lawful to download (e.g. sexual content, copyright works)
Lawful to keep (e.g. “old” personal data)
Safe to download (e.g. not virus ridden)
Safe to keep (e.g. does not impugn system by interfering with interoperability)

14. Version Control
File referencing – file must be named in a way that allows it to be easily identified and found
File location – everything must be saved on server drive in an appropriately named folder
Folder referencing – folders should be appropriately named so that they can be found and identified easily
Revision and version numbering – always go up a version and always use track changes.
Ownership – each document must have an identified document owner
House style

15. Challenges of a Paper Light Environment
Gradually reducing dependence on paper
Introducing a managed and cost-effective digitisation programme.
Not a linear journey
Expensive and unnecessary to digitise everything – start on important documents
Identify and collect ‘inactive’ paper – those documents that you no longer need or are unlikely to access
Now get them out of the office into a secure environment where the paper can be managed against defined retention periods but still accessed if required
People keep information close to hand because they want to refer to it regularly or get to it quickly
They need an acceptable alternative that combines ease of access with the benefits of secure storage and management
Tackle information at the point at which it comes into the business and ensuring the data can feed directly into automated processes or workflows.
Inbound scanning
Acting in stages will make the challenge more manageable